AUB News

On October 30, 2025, the Association of Ukrainian Banks held a meeting of the Committee on Accounting, Auditing, and Taxation, which was attended by more than 55 representatives of banks. The participants discussed topical issues related to the implementation of the SAF-T UA standard audit file, the technical readiness of tax authorities, and the protection of banking information. The main purpose of the meeting was to discuss further steps to resolve issues related to the implementation of SAF-T UA, as well as to form a common position of the banking sector for constructive dialogue with the State Tax Service of Ukraine.

The implementation of SAF-T UA is one of the key stages in the digitization of tax reporting. This tool is designed to increase the transparency of financial data and simplify interaction with tax authorities. At the same time, it poses a number of challenges for banks, ranging from technical difficulties to the risk of confidential information being disclosed. That is why the Association of Ukrainian Banks initiated a public discussion to develop a unified, coordinated position for the industry.
The issues discussed concerned the readiness of the State Tax Service to accept SAF-T UA files, technical errors during reporting, and the legal aspects of disclosing banking data.

During the discussion, issues were raised regarding the unification of file formation methods, differences in bank account plans, excessive “controls” in the State Tax Service system, and the need for a phased implementation of SAF-T UA.
The Committee members also drew attention to legal conflicts — ambiguous interpretations of banking secrecy, the term “banking operation,” and the amount of information that banks can transfer to tax authorities. In this context, the need to coordinate actions with the National Bank of Ukraine and, if necessary, involve the relevant committee of the Verkhovna Rada was emphasized.

Committee Chairman Bohdan Lukashevych stressed that the importance of this issue lies in defining uniform standards for working with data that would simultaneously meet the requirements of tax legislation and not violate banking secrecy.
Summing up the meeting, the participants agreed to consolidate the position of the banking community. In the coming days, banks and non-bank financial institutions will provide the AUB with a list of specific problems, errors, and proposals, which will be systematized for joint work with the State Tax Service.
Bogdan Lukashevich summed up that only through the joint efforts of the banking sector, the State Tax Service, and the NBU can a practical, secure, and technologically feasible reporting mechanism through SAF-T UA be developed.

The Association's next steps include preparing a joint letter to the State Tax Service of Ukraine with a detailed description of the problems identified and proposals received from banks and non-bank financial institutions. In addition, the Association will initiate a working meeting with the Audit Department of the State Tax Service in a narrow format for a substantive discussion of issues related to the technical readiness of the SAF-T UA system. It is planned to involve the National Bank of Ukraine in the process for joint consideration of banking secrecy issues, and the possibility of conducting pilot testing of SAF-T UA interfaces with the participation of AUB member banks is also being considered in order to verify the effectiveness and practical implementation of new approaches to reporting.

For reference:

SAF-T UA (Standard Audit File for Tax) is a standard audit file for tax purposes, created based on the international OECD SAF-T format. Its purpose is to ensure uniform electronic exchange of financial data between businesses and tax authorities.
The SAF-T UA format requires companies, including banks and non-bank financial institutions, to generate a special electronic file containing structured accounting data necessary for verifying tax liabilities. This allows for the automation of auditing and reporting, reduces the number of manual checks, and increases the transparency of financial reporting.

In addition, the Association is initiating a working meeting with relevant specialists from the State Tax Service in a narrow format for a substantive discussion of issues related to the technical readiness of the SAF-T UA system. It is planned to involve the National Bank of Ukraine in the process to jointly develop a definition of the concept of secrecy.